Permit Processing Steps 


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Basic steps to obtain Ohio EPA air pollution permits

The following describes the general procedures used to obtain Ohio EPA air pollution permits. These steps are general in nature and cannot contain all of the steps involved in obtaining permits. The time needed for each step can be highly variable depending on current work loads at the various Ohio EPA offices.

  1. To be done 2 years to 4 months before construction is scheduled to start. (2 years if it is a very large air pollution source, 4 months for small air pollution sources.)
    • Contact the local EPA office and discuss the proposed source. Discuss permitting, permit fees, permit processing time, application forms, air monitoring requirements, emissions testing requirements, possible regulations, obvious permit limits and any other pertinent information.
  2. To be done 3 to 6 months before construction starts for most sources, 2 years for major air pollution sources.
    • Complete the PTI/PTIO application and submit to the Ohio EPA. Include any necessary supporting documentation. (You may want to contact the Ohio EPA District Office or Local Air Agency (DO/LAA) and confirm that the data you plan to submit is sufficient.)
  3. This step is done only after the Ohio EPA receives a complete application.
    • Ohio EPA DO/LAA reviews the application, determines if the new installation will comply with the applicable regulations, and develops any necessary terms and conditions. If additional information is needed, the local office contacts the company for the information and waits for the information before proceeding.
  4. This step occurs typically 1 to 3 months from the date the complete application was submitted depending on the current backlog of permits at the DO/LAA level.
    • The Ohio EPA DO/LAA sends a recommendation to the Ohio EPA Central Office. The Central Office does their technical review of the application. If it is approvable, a draft or a final PTI or PTIO is issued. If it is not approvable, it is sent back to the DO/LAA to be corrected. Depending on the Central Office backlog, this process could take from 2 weeks to 2 months.
  5. This occurs 1 to 3 months from the date the complete applications was submitted.
    • For large sources and certain types of sources the Ohio EPA issues a draft permit. At the same time, the Ohio EPA puts a notice in the local paper detailing the proposed installation. This notice solicits comments from the public and allows 30 days for anyone to comment. A public meeting may also be held at this point. If no comments are received, then the process goes on to step 6. Otherwise the permit is either modified and reissued as a draft (steps 4 and 5) or the permit is denied.
  6. This occurs 1 to 6 months from the date the complete application was submitted.
    • The Ohio EPA then issues a final PTI or PTIO. This permit allows the company to begin construction of the new source and for a PTI, to operate it for the purposes of testing the emissions; and for a PTIO, operate for up to ten years depending on the renewal cycle.
  7. This time varies depending on the construction schedule.
    • The source is installed. Any required emissions testing is conducted. 

Note: Title V facilities may be required to submit a revised Title V application and (in some cases) be issued a revised Title V permit before beginning operation after issuance of a PTI. For information on Title V revisions, please see the Guidance for Incorporating Facility Changes into a Title V Permit.

Permits to Install

Once a permittee has completed a Permit to Install application and submitted it to the appropriate local Ohio EPA District Office or Local Air Agency (DO/LAA), it is assigned to a permit review engineer and is reviewed for the following:

Permit Engineer Review

1. Completeness of the application

2. Identification of any controversial issue(s)

3. Identification of the applicable air pollution regulations

4. A check of the emissions calculations for accuracy

The DO/LAA then submits the recommendation with a tracking form to the Ohio EPA Central Office, Permit Management Unit (PMU). The permit recommendation is then processed as follows:

For Direct Finals, Gasoline Dispensing Facilities, and Registrations:

1. The permit is logged into the Air Permitting System (APS) computer tracking system

2. A file is then created for the permit

3. The permit recommendation is released to the "Air Quality Modeling and Planning" (AQM&P) Section to be assigned to a review engineer for regulatory review

4. The permit recommendation is forwarded to the PMU to be typed, upon being approved by the review engineer in AQM&P

5. The PMU logs the permit back in the APS as "review completed," and completes a final check for any discrepancies, (i.e., accuracy of fees, address, etc.), and the permit is typed, issued and public noticed as a "Final Action."

"Draft Permits" are processed as follows:

1. The permit is logged into the Air Permitting System (APS) computer tracking system

2. A file is then created for the permit

3. The permit recommendation is released to the "Air Quality Modeling and Planning" (AQM&P) Section to be assigned to a review engineer for regulatory review

4. The permit recommendation is forwarded to the PMU to be typed, upon being approved by the review engineer in AQM&P;

5. The PMU logs the permit back in the APS as "review completed," and completes a final check for any discrepancies, (i.e., accuracy of fees, address, etc.). The permit is then typed and issued as a "Draft Action" of the Director;

6. Once a "Draft" is issued, it is public noticed for "30-days"; the public, facility, USEPA, and affected adjoining states can comment on the "Draft Permit" during this period; some permits may even have a "public hearing" held regarding the construction of the facility;

7. Once the comment period is over, the DO/LAA receives a "Proof of Publication" Interoffice Communication from the Ohio EPA Legal records section; sends a Final Recommendation along with a copy of the Proof of Publication to the PMU; indicates whether or not any comments have been submitted by the public, facility, or USEPA; and indicates whether or not the "Draft language" has been changed as a result of any comments received;

8. The PMU logs the permit back into the APS and the "Final Recommendation" is combined with the "Draft" permit file and released to the AQM&P section for review as a "Final Action" to be approved for "Final Issuance"; and,

9. Upon approval by AQM&P, the PMU logs the permit back in the APS as "review completed," and the permit is edited if necessary with any changes that need to be made, issued, and public noticed as a "Final Action of the Director."

PMU also processes "Time Extensions; Modifications - Draft and Final; Revocations and Corrected Copies" of Permits to Install.

 

Permits to Operate

Permits to Operate are processed as follows:

1. The permittee submits an application either electronically or as a hard copy

2. If the application is submitted electronically, the permittee then mails a "Verification of Receipt" to the DO/LAA

3. Once this has occurred the application is then added to the State Air Resources System (STARS) to be assigned to a permit review engineer at the appropriate DO/LAA

4. The permit review engineer performs a completeness and/or technical review of the application

5. The permit review engineer then develops the permit terms and conditions and submits their recommendation to their Supervisor for the appropriate type of permit (State, Title V, FESOP, or to place the emissions unit on Registration status)

6. Once approved by the DO/LAA Supervisor, the permit recommendation is then forwarded to Ohio EPA Central Office, Engineering Section for review

7. The central office review engineer then reviews the permit terms for completeness and/or technical issues

8. The review engineer then submits a recommendation to the Central Office Engineering Section Manager for approval

9. Once the Engineering Section Manager has reviewed the permit and approved the permit terms and conditions, he then locks the document(s) and forwards the permit(s) to the PMU

10. The PMU issues the permit and public notices the permit as a "Final action of the Director."

Draft FESOPs are processed as follows:

1. The permittee submits an application either electronically or as a hard copy

2. If the application is submitted electronically, the permittee then mails a "Verification of Receipt" to the DO/LAA

3. Once this has occurred the application is then added to the State Air Resources System (STARS) to be assigned to a permit review engineer at the appropriate DO/LAA

4. The permit review engineer performs a completeness and/or technical review of the application

5. The permit review engineer then develops the permit terms and conditions and submits their recommendation to their Supervisor for the appropriate type of permit (State, Title V, FESOP, or to place the emissions unit on Registration status)

6. Once approved by the DO/LAA Supervisor, the permit recommendation is then forwarded to Ohio EPA Central Office, Engineering Section for review

7. The central office review engineer then reviews the permit terms for completeness and/or technical issues

8. The review engineer then submits a recommendation to the Central Office Engineering Section Manager for approval

9. Once the Engineering Section Manager has reviewed the permit and approved the permit terms and conditions, he then locks the document(s) and forwards the permit(s) to the PMU

10. Once a "Draft" permit document is issued, it is public noticed for "30-days"; the public, facility and USEPA can comment on the "Draft Permit" during this period

11. Once the comment period is over, the PMU receives a "Proof of Publication" Interoffice Communication from the Ohio EPA Legal records section and this is entered into the FESOP tracker program; the permit review engineer also receives a copy of the "Proof of Public Notice" and creates the "Final Terms and Conditions" based on whether or not their were any comments received and submits it to their Supervisor for approval

12. The DO/LAA Supervisor forwards the "Final Terms and Conditions" to the Ohio EPA Central Office Engineering Section Manager for final approval

13. The Ohio Central Office Engineering Section Manager reviews the "Final Terms and Conditions document" locks it and forwards it to the PMU

14. PMU then issues the "Final Permit" as a "Final Action of the Director", and public notices it.

"Title V Permits" are processed as listed below:

1. The permittee submits an application electronically

2. If the application is submitted electronically, the permittee then mails a "Verification of Receipt" to the DO/LAA

3. Once this has occurred the application is then added to the State Air Resources System (STARS) to be assigned to a permit review engineer at the appropriate DO/LAA

4. The permit review engineer performs a completeness and technical review of the permit application

5. The permit review engineer develops the permit terms and conditions and submits their recommendation to their Supervisor

6. Once approved by the DO/LAA's Supervisor, the permit recommendation is then forwarded to Ohio EPA Central Office, Engineering Section for review

7. The central office review engineer then reviews the permit terms for completeness, regulatory and/or technical issues

8. The central office review engineer then submits a recommendation to the Central Office Engineering Section Manager for approval

9. Once the Engineering Section Manager has reviewed the permit and approved the permit terms and conditions, he then locks the document(s) and forwards the permit(s) to PMU

10. Once the "Draft" permit document is issued, it is public noticed for "30-days"; the public, facility, affected surrounding states and USEPA can comment on the "Draft Permit" during this period

11. Once the "Draft" comment period is over, the DO/LAA permit engineer creates the "Preliminary Proposed Terms and Conditions document" after addressing any comments received from the public, facility, affected surrounding states or USEPA, and submits it to their Supervisor for approval

12. The DO/LAA Supervisor modifies and/or approves the "Preliminary Proposed Terms and Conditions document" and forwards it to the Ohio EPA Central Office Engineering Section for approval

13. The Engineering Section reviews and approves the "Preliminary Proposed Terms and Conditions document," locks it and forwards it to the PMU for issuance

14. The "Preliminary Proposed Permit" is then issued to the facility. A copy of the "Preliminary Proposed Permit" is also sent to the DO/LAA. The facility then has fourteen (14) days from receipt of the permit to request a meeting if desired. If a request for a meeting is not received by the DO/LAA within fourteen (14) days of receipt of the letter, a Proposed Permit (as written, or with agreed-upon changes) is created by the DO/LAA, approved by the Central Office Engineering Section and sent to the USEPA via STARS for approval as a "Proposed Permit"

15. Once the "Proposed Permit" is created and has been submitted by DAPC, the USEPA, has forty-five (45) days from USEPA's receipt of the certified letter to review the "Proposed Permit." If the USEPA has no objection to the "Proposed Permit," a "Final Permit" will be issued

16. The "Final Permit" is created electronically by the PMU, locked and issued to the facility, with a copy to the DO/LAA and USEPA. Issuance of the "Director's Final Action" is public noticed and is appealable to the Environmental Review Appeals Commission.

PMU also processes Modifications - Draft and Final; Revocations, Denial, and Variance to Operate.

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